Commentary

D8.323 Qualifying issuing companies—trading activities requirement: generally

Corporate tax
Corporate tax | Commentary

D8.323 Qualifying issuing companies—trading activities requirement: generally

Corporate tax | Commentary

D8.323 Qualifying issuing companies—trading activities requirement: generally

Throughout the qualification period, the issuing company must satisfy the trading activities test1. The terms of the requirement depend on whether the issuing company is a single company (that is, a company which is not a member of a group2) or a parent company.

Single companies

In the case of a single issuing company, it must exist only to carry on qualifying trades. As to what is a qualifying trade, see D8.324. Any incidental purposes of the company can be disregarded; purposes are incidental in this context if they have no significant effect on a company's other (non-incidental) activities3.

The holding or managing property that the company uses for a

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